Justia Juvenile Law Opinion Summaries

Jerad Parks was charged with first degree sexual assault on a child. Although Parks was twenty-four years old at the time he was charged, he filed a motion to transfer to the juvenile court because he was a juvenile at the time of the offenses. The district court denied the motion. Parks then pled no contest to attempted second degree sexual assault and felony child abuse. The district court ordered Parks to register as a sex offender under the Sex Offender Registration Act (SORA). The Supreme Court affirmed, holding (1) the district court did not err in denying Parks' motion to transfer because under the plain language of the juvenile code, the juvenile court's jurisdiction ends when the juvenile reaches the age of majority; and (2) because Parks pled no contest to a registrable offense under SORA, the plain language of the statute required Parks to register as a sex offender. View "State v. Parks" on Justia Law

Defendant Jesse Pearson, a seventeen-year-old, robbed and beat an elderly man. After he was apprehended, Pearson refused to waive his Miranda rights. The next morning, however, he confessed to his social worker, Marie Mahler, without his attorney present. The district court denied Pearson's motion to suppress his confession, concluding that Mahler's interview was not a custodial interrogation implicating Miranda safeguards. A jury convicted Pearson of first-degree robbery, willful injury, and going armed with intent. The court of appeals reversed Pearson's conviction on the going armed charge and otherwise affirmed. At issue on appeal was whether Pearson's confession to Mahler was admissible. The Supreme Court affirmed, holding that Mahler's interview of Pearson was not a custodial interrogation for Miranda purposes and that his confession to her was voluntary and admissible. View "State v. Pearson" on Justia Law

n this appeal, the issue before the Supreme Court was whether the mere offer of an automobile ride to a child constituted an attempt to “lure” the child under Section 2910 of Pennsylvania’s Criminal Code, entitled “Luring a child into a motor vehicle or structure.” Appellant was charged with four counts of harassment, stalking, and attempted luring of a child into a motor vehicle for offering two neighborhood boys a ride to school in Appellant's own neighborhood. He had seen the children in the neighborhood, and offered them short rides to school or to the store. The children declined, and Appellant made no further attempt to "help." Appellant was acquitted of the charged at a bench trial because the judge "expressly stated she found no evidence that Appellant had any intent to harm the children, and that she believed 'the circumstances show no reason to believe that this defendant had any evil or improper intent in doing what he did.'” However, on the sole basis of Appellant’s offer of the rides, she convicted him on all four counts of attempted luring. The trial court found that “[Appellant’s] offer of a ride to the victims is sufficient to constitute an attempt to ‘lure.’” The trial court subsequently sentenced Appellant to 18 months’ probation. As an automatic result of his convictions, Appellant was statutorily mandated to register for ten years as a sex offender under Megan’s Law. Appellant filed an appeal to the Superior Court, arguing that the evidence was insufficient as a matter of law to sustain his conviction, because his offer of a ride to the children, by itself, did not constitute a “lure” or an attempt to “lure,” given that he did not offer the children any enticement to get into his car, nor did he command or otherwise threaten them. Appellant also argued that he had no ill intent in offering the children a ride, but, rather, was merely acting as a “disabled Good Samaritan.” After careful review, the Supreme Court concluded that an attempt to “lure” does not include the action of simply extending an offer of an automobile ride to a child, when it is unaccompanied by any other enticement or inducement for the child to enter the motor vehicle. Consequently, the Court reversed Appellant's conviction for attempted luring. View "Pennsylvania v. Hart" on Justia Law

Defendant was convicted and sentenced to death in 1995 for murder. Because defendant was seventeen years old at the time of the murder, the state court eventually set aside his death sentence and resentenced him to life imprisonment. On appeal, defendant contended that his life without parole sentence was an unconstitutional penalty for him because he was not yet eighteen years old at the time he committed the murder. The court held that it owed 28 U.S.C. 2254(d)(1) deference to the state trial and appellate court decisions that defendant's life without parole sentence, and the procedures under which it was imposed, were not unconstitutional in light of the Roper v. Simmons decision. View "Loggins v. Thomas, et al." on Justia Law

Defendant, who was under fourteen-years-old at the time of the alleged offense, was subsequently indicted when defendant was twenty-three-years-old on six charges of rape of a child with force and two charges of indecent assault and battery on a child under the age of fourteen. At issue was whether a person who committed an offense at an age under 14, but who was not apprehended until after he or she had passed the age of 18, could be prosecuted. The court held that the Superior Court had jurisdiction to try the person for that offense under G.L.c. 119, section 72A, after indictment, provided that a judge in the Juvenile Court had determined that there was probable cause to believe that the person committed the offense charged and that the interests of the public required that the person be tried for the offenses instead of being discharged. Accordingly, the court remanded for further proceedings. View "Commonwealth v. Porges" on Justia Law

D.J.M., a student in the Hannibal Public School District #60 (district), sent instant messages from his home to a classmate in which he talked about getting a gun and shooting some other students at school. After D.J.M. was subsequently suspended for ten days and later for the remainder of the school year as a result of his actions, D.J.M.'s parents sued under 42 U.S.C. 1983, alleging that the district violated D.J.M.'s First Amendment rights. At issue was whether the district court properly granted summary judgment to the district on D.J.M.'s constitutional claims and remanded his state claim for administrative review. The court held that D.J.M. intentionally communicated his threats to a third party and the district court did not err in finding that they were true threats. The court also held that true threats were not protected under the First Amendment and the district was given enough information that it reasonably feared D.J.M. had access to a handgun and was thinking about shooting specific classmates at the high school. Therefore, in light of the district's obligation to ensure the safety of its students and reasonable concerns created by shooting deaths at other schools, the district court did not err in concluding that the district did not violate the First Amendment by notifying the police and subsequently suspending him after he was placed in juvenile detention. The court further held that it was reasonably foreseeable that D.J.M.'s threats would be brought to the attention of school authorities and created a risk of substantial disruption within the school environment. The court finally held that it was not an abuse of discretion to dismiss the state law claim as moot. Accordingly, the judgment of the court was affirmed. View "D.J.M., et al. v. Hannibal Public Sch. Dist., et al." on Justia Law

Defendant, 16 years-old at the time, appealed his juvenile delinquency conviction on two counts of aggravated assault of his four year old nephew (J.D.). On appeal, defendant contended that J.D.'s refusal to identify him as the perpetrator created ipso facto reasonable doubt as to his guilt, and thus rendered the district court's judgment unsupported by the evidence. The court held that there was nothing in the record to suggest that the district court's credibility determination was so erroneous as to merit reversal and combining this credibility assessment with the other evidence in the record, the court found that defendant's conviction was supported by sufficient evidence. Therefore, a reasonable fact-finder could find that defendant was guilty on this evidence and thus, the court affirmed the judgment of the district court. View "United States v. B.A.D." on Justia Law

K.C., a juvenile, was adjudged delinquent. As part of her disposition, she was allowed to remain in a home environment and placed on supervised probation. After K.C. violated various terms of her probation, her probation was revoked and her disposition changed to placement at a state girls' school for an indefinite period. K.C. appealed. The Supreme Court affirmed, holding (1) the juvenile court did not abuse its discretion in imposing sanctions because placement at the girls' school fell within the statutorily allowable sanctions applicable to K.C. and, thus, the court was not required to provide a written justification for the placement; (2) the juvenile court's consideration of a statement K.C. made that she would not follow the rules of a residential program did not violate K.C.'s right against self-incrimination because the statement was considered only in the dispositional phase of the delinquency proceedings; and (3) there was no violation of Wyo. R. Crim. P. 11 because the rule does not apply to juvenile delinquency proceedings. View "In re K.C." on Justia Law

Petitioner, a juvenile, was convicted for trespassing upon the grounds of a school facility in violation of section 810.097(2), Florida Statutes. At issue was whether the prosecution must prove the identity of the individual who warned defendant to leave the grounds of the school, and that individual's authority to restrict access to the property, as essential elements of the trespass offense. The court held that the individual's identity and authority were essential elements of the offense and quashed the decision of the Third District. The court also held that, because in this case the state failed to present any evidence demonstrating that the petitioner was warned to leave by the school's principal or a designee of the principal, petitioner's conviction must be vacated. View "D.J. v. State" on Justia Law

Sixteen-year-old Defendant Oden Gutierrez confessed to shooting and killing Thomas Powell in Powell's home and stealing his car. Defendant was charged by criminal information with an open charge of murder, aggravated burglary, armed robbery for stealing a car while armed with a deadly weapon, and unlawful taking of a motor vehicle. A jury found him guilty on all counts and he was sentenced to life in prison plus nineteen and one-half years. Defendant appealed his sentence. He raised several issues which fell into four categories: (1) the suppression of evidence pertaining to his confession; (2) change of venue due to prejudicial pre-trial publicity; (3) a double jeopardy violation for his convictions of both armed robbery and the unlawful taking of a motor vehicle; and (4) an unlawful sentence based on constitutional grounds, mainly that a life sentence was cruel and unusual punishment for a youthful offender. Upon careful consideration of Defendant's arguments, the trial record, and the applicable legal authority, the Supreme Court reversed Defendant's sentence and remanded the case for re-sentencing with instructions that a pre-sentence report be prepared. The Court also vacated Defendant's conviction for unlawful taking of a motor vehicle because it violated the proscription against double jeopardy in this case. The Court affirmed the district court on all other issues. View "New Mexico v. Gutierrez" on Justia Law